CMS Guidelines and the Impact on Workers' Compensation

The Centers for Medicare and Medicaid Services published an Alert, inviting public comment on draft language that defines, with specificity, the conditions that lead to designation of an applicable plan as a Responsible Reporting Entity.

By Paul J. Masterson, Glenn W. Simpson|August 19, 2009 at 08:00 PM

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Pursuant to the Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSEA), the Centers for Medicare and Medicaid Services (CMS) published an Alert, dated July 31, 2009, inviting public comment on draft language that defines, with specificity, the conditions that lead to designation of an applicable plan as a Responsible Reporting Entity (RRE). The period of time for public comment was until August 16. The language, once finalized, will be incorporated into the CMS User Guide for Non-Group Health Plans (NGHP), which was first published in March.

Liability insurance (including self-insurance), no fault, and workers’ compensation are under the overall umbrella of NGHP and the attendant reporting requirements as described and mandated in the Act. The Alert contains important examples of scenarios involving deductibles, fronting policies, private payments and the like that can lead to designation of an insured as a plan and thus as an RRE with an obligation to file Section 111 reports in accord with CMS protocols and requirements. Further, the draft language contains guidance and definitions that apply specifically to workers’ compensation.